Privacy Policy

This Website provides information about PM Dragonfly’s general business, software, products, or services. If you have any questions about PM Dragonfly’s collection of your data, please contact us at info@pmdragonfly.com.

Introduction

Any data collected through pmdragonfly.com Website (the “Website”), including Personal Data, will only be used when you register, request information or a response from PM Dragonfly to better understand your needs for further sales and marketing opportunities. Once collected, Personal Data will not be used for a different incompatible purpose without your consent. PM Dragonfly Ltd (14111108) 2D Zetland House, 5-25 Scrutton Street, London, EC2A 4HJ, is regarded as the Data Controller.

PM Dragonfly Ltd is registered with the Information Commissioner’s Office (ICO) under registration number ZC257844. We have not appointed a Data Protection Officer. Please send any privacy questions to info@pmdragonfly.com.

We take the protection of data privacy very seriously. All Personal Data collected through the Website application will be treated as strictly confidential and will only be used as set out in this Privacy Policy. The applicable data protection laws shall be respected in full, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR), as amended by the Data (Use and Access) Act 2025. Therefore, please read this Privacy Policy thoroughly. If you disagree with the way Personal Data will be used, please do not use this Website or provide your Personal Data through the Website.

Purpose of data collection

The main purposes of collecting Personal Data through the Website are for marketing and sales reasons. Furthermore, your Personal Data can be used for analytics purposes, such as analysing traffic on the Website.

Separately, we collect Personal Data for Website security and maintenance.

We also use Personal Data to send you marketing communications about our services (see “Marketing communications” below), and to respond to and manage any requests to exercise your rights or any complaints you make.

What Personal Data do we collect and process?

Personal Data means any information relating to an identified or identifiable natural person (i.e. a living individual).

We collect the following Personal Data from you: your name, your email, your job title, your company name and your reason for contacting us.

If you download gated content from the Website, such as a whitepaper, we also collect the details you enter in the download form.

Browsing Information: We additionally collect limited Personal Data connected with your use of the Website, e.g. IP address, browser type, operating system, referring domains and exit links.

Cookies and similar technologies: We collect information through cookies and similar technologies, as explained in the “Cookies and similar technologies” section below.

We do not intentionally collect special category data (such as information about health) through the Website. The Website is intended for business users and is not directed at children.

What legal ground(s) do we rely on?

You always have a choice concerning whether or not you provide Personal Data. You do not have to give us your Personal Data. If you do not, we won’t be able to respond to your enquiry.

When you contact us, we rely on our legitimate interests in responding to you, or on taking steps at your request before entering into a contract with you. We rely on consent only for non-essential cookies and, where the law requires it, for marketing. You can withdraw that consent at any time without affecting anything we have already done.

The use of the Personal Data is further necessary for the purposes of PM Dragonfly's legitimate interest in improving our services, so we can better understand your needs and expectations and therefore improve our services to you; to prevent fraud and to ensure that the use of our web services is complete and without fraudulent behaviour; to ensure the security of our services and to ensure that our offerings are technically secure and functioning properly.

We may also rely on our legitimate interest in direct marketing to send relevant information about our services to business contacts, where PECR allows this (see “Marketing communications” below). Where we rely on legitimate interests, we have balanced our interests against your rights and freedoms, and you have the right to object at any time.

Where we need to keep or share Personal Data to comply with the law, we rely on legal obligation. We only place non-essential cookies on your device with your consent (see “Cookies and similar technologies” below).

With whom do we share Personal Data?

We will share your Personal Data with employees of PM Dragonfly, including Sales, Marketing, IT and Operations Teams in order to provide you with the required service. We will not disclose your Personal Data to anyone else under any circumstances except as otherwise stated in this Privacy Policy, to successors in title to our business, to establish, exercise or defend our rights, or where required by law.

This includes trusted service providers who help us run the Website and our business, such as our website host (Wix), our customer relationship management (CRM), email marketing and website tracking platform (HubSpot), website analytics providers (such as Google), LinkedIn (through the LinkedIn Insight Tag, which measures our advertising) and our cookie consent provider (Usercentrics). HubSpot and LinkedIn tracking only runs if you accept marketing cookies. We do not sell your Personal Data.

We may also share Personal Data with our professional advisers, and with regulators or law enforcement where the law requires it.

Who is processing the Personal Data?

Employees of PM Dragonfly (from Sales, Marketing, IT and Operations) are processing your data. Any processing of your Personal Data by these employees is in accordance with our instructions.

If the services of third parties for the technical maintenance, administration or processing of data are required, the Personal Data will be accessed by these parties only to the extent that is required to ensure a smooth and secure technical handling of the Website and in compliance with applicable law, including with respect to data confidentiality, privacy and security. These third parties act on our instructions under written contracts.

Your rights regarding your Personal Data

You may exercise the following legal rights regarding any Personal Data that we hold about you.

The right of access
The right to rectification
The right to erasure
The right to object (including an absolute right to object to direct marketing)
The right to restrict processing
The right to data portability
The right to withdraw your consent to the processing of your Personal Data at any time
Rights relating to automated decision-making. We do not make decisions about you through the Website based solely on automated processing that have legal or similarly significant effects.

Your right to object: you can object at any time to our use of your Personal Data where we rely on legitimate interests, and you can always object to direct marketing. Email info@pmdragonfly.com or use the unsubscribe link in any of our emails.

Please contact info@pmdragonfly.com if you want to make use of any of your above-mentioned legal rights.
We will respond without undue delay and within one month of receiving your request. We may extend this by up to two further months if your request is complex or you make several requests, and we will tell you if we do. If we need more information to confirm your identity or understand your request, the time limit starts once we receive it. We will carry out reasonable and proportionate searches for your Personal Data. There is usually no charge.

If you think that we are not compliant with the principles set out in this Privacy Policy, if you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority. In the UK, this is the Information Commissioner’s Office (see “Making a complaint” below).

Making a complaint

If you are unhappy with how we have handled your Personal Data, you have the right to complain to us. Please contact us at info@pmdragonfly.com or write to us at the address above, although we will accept complaints however you send them. We will:

acknowledge your complaint within 30 days of receiving it;
look into it without undue delay;
keep you updated on our progress; and
tell you the outcome.

This follows the complaints duty under the Data (Use and Access) Act 2025.
You also have the right to complain to the Information Commissioner’s Office (ICO). If you are outside the UK, you can complain to the data protection regulator in your own country.

How long do we keep your Personal Data?

We only keep Personal Data for as long as we need it for the purposes set out in this Privacy Policy. As a guide:

Enquiry and contact details: 24 months from our last meaningful contact with you, unless you become a client, in which case our client retention periods apply.
Client contracts and invoices: 6 years from the end of the financial year they relate to, as required by the Companies Act 2006.
Marketing contacts: until you unsubscribe or object. We keep a minimal record of your details so that we do not contact you again.
Records of complaints and rights requests: 2 years after the matter is closed.
Website analytics data: 14 months.
Cookies: as set out in our cookie settings and the “Cookies and similar technologies” section below.

Data Security

We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, to secure your data against loss or damage and to help protect the accuracy and security of Personal Data and to prevent unauthorised access or improper use. If you think that the Website or any Personal Data is not secure or that there has been unauthorised access to the Website or your Personal Data, please contact info@pmdragonfly.com immediately.

Our Website is hosted by Wix, which protects it with firewalls and intrusion prevention systems, encryption of data in transit (TLS 1.2 or above) and at rest (AES-256), 24/7 security monitoring and DDoS protection.

Confidentiality

Please note that we treat Personal Data as strictly confidential.

Data Transfers

Your Personal Data may be transferred to the US, which is not considered to have the same level of data protection as in the UK (except for US organisations certified under the UK Extension to the EU-US Data Privacy Framework). However, we ensure all data transfers comply with applicable legal requirements. Where Personal Data is transferred outside the UK, we protect it by relying on UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework, where the recipient is certified) or on appropriate safeguards such as the ICO’s International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Should you wish to know more about how data is protected or wish to request a copy of the contractual protections, please contact info@pmdragonfly.com.

Cookies and similar technologies

Cookies are small text files placed on your device when you visit a website. We and our service providers use cookies and similar technologies (such as tags and pixels) on the Website. When you first visit, our cookie banner lets you accept or reject non-essential cookies. We will not set non-essential cookies unless you agree.

A full list of the cookies we use, including their names, who sets them and how long they last, is in our cookie settings. To open them, select the fingerprint icon at the bottom left of the screen.

You can change your cookie choices at any time. Select the fingerprint icon at the bottom left of any page on the Website to open your cookie settings, then turn each type of cookie on or off. You can also block or delete cookies through your browser settings. Blocking some cookies may affect how the Website works. Where the law allows us to use certain analytics or functionality technologies without consent, we will always tell you about them here and give you a simple, free way to object.

Marketing communications

We only send marketing about our own services. We will only send you marketing emails where you have agreed to receive them, or where you work for a company and the law allows us to contact you at your work email address. If you are a sole trader or partnership, please tell us, and we will only send you marketing emails with your consent, or if you have bought similar services from us and did not opt out. Every marketing email includes an unsubscribe link. You can also opt out at any time by emailing info@pmdragonfly.com, and we will stop straight away.

If you download content such as a whitepaper using a company email address, we may also send you related insights about our services. We will tell you this when you download, and you can opt out at any time.

Notification of changes

Should we wish to change this Privacy Policy, if you have already provided Personal Data through this Website, we will contact you to inform you of the new Privacy Policy and, in some circumstances, we may need to obtain your consent to the changes. In other circumstances, any such changes to this Privacy Policy will be promptly communicated on this page, and you should check back to see whether there are any changes. Continued use of the Website after a change in the Privacy Policy indicates your acknowledgement and acceptance of the use of Personal Data in accordance with the amended Privacy Policy.

This does not affect your rights under data protection law.

Further Information

For further information on PM Dragonfly, please visit our Website www.pmdragonfly.com
If you consider that we are not complying with this Privacy Policy or if you have any questions in relation to this Privacy Policy, please contact info@pmdragonfly.com. You may also lodge a formal complaint with your competent data protection authority (in the UK, the Information Commissioner’s Office, see “Making a complaint” above).

Last updated: 16 October 2026